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9 Minnesota opinions name it 2 courts 2004–2016 0 in the last five years
The cases below were cited by Minnesota courts in a sentence that names this issue. Sides come from how each citing opinion treated the case (Syfertize flag on that citation), so a case can appear on both: that is where the law is contested. A red or yellow chip is the case's own overall treatment.
| Case | Followed | Cited |
|---|---|---|
State v. Fergusongreen2 sentences2016State v. Ferguson, 808 N.W.2d 586, 589 (Minn. 2012) (“[T]he legislature did not intend section 609.035 to immunize offenders in every case from the consequences of separate crimes intentionally committed in a single episode against more than one individual.” (quotation omitted)). 2013The purpose of Minnesota Statutes section 609.035 (2010), often referred to as the single-behavioral-incident rule, “is to protect against exaggerating the criminality of a person’s conduct and to make both punishment and prosecution commensurate with culpability.” Ferguson, 808 N.W.2d at 589 (quotation omitted). | 2 | 2 |
State v. Williamsgreen2 sentences2014“When conducting a single-behavioral-incident analysis for two intentional crimes, Minnesota courts consider whether the conduct (1) shares a unity of time and place and (2) was motivated by an effort to obtain a single criminal objective.”1 State v. Bauer, 776 N.W.2d 462, 478 (Minn. App. 2009) (citing State v. Williams, 608 N.W.2d 837, 841 (Minn. 2000)), aff’d, 792 N.W.2d 825 (Minn. 2011). 2009State v. Williams, 608 N.W.2d 837, 841 (Minn.2000); State v. Soto, 562 N.W.2d 299, 304 (Minn.1997). | 2 | 2 |
State v. Holmesgreen1 sentence2016See State v. Holmes, 778 N.W.2d 336, 340-41 (Minn. 2010) (interpreting Minn. Stat. § 609.585 (2008)). | 1 | 1 |
State v. Skipinthedaygreen1 sentence2015Under the multiple-victim exception, a district court may impose “multiple sentences for multiple crimes arising out of a single behavioral incident if: (1) the crimes affect multiple victims; and (2) multiple sentences do not unfairly exaggerate the criminality of the defendant’s conduct.” State v. Skipintheday, 717 N.W.2d 423, 426 (Minn. 2006). | 1 | 1 |
State v. Bauergreen1 sentence2014“When conducting a single-behavioral-incident analysis for two intentional crimes, Minnesota courts consider whether the conduct (1) shares a unity of time and place and (2) was motivated by an effort to obtain a single criminal objective.”1 State v. Bauer, 776 N.W.2d 462, 478 (Minn. App. 2009) (citing State v. Williams, 608 N.W.2d 837, 841 (Minn. 2000)), aff’d, 792 N.W.2d 825 (Minn. 2011). | 1 | 1 |
In Re Brittaingreen1 sentence2013We conclude that section 609.035, subdivision 3, is unambiguous in stating that neither the single-behavioral-incident rule nor section 609.04 is “a bar to conviction of or punishment for any other crime committed by the defendant as part of the same conduct.” (Emphasis added.) “The word ‘any’ is given broad application in statutes, regardless of whether we consider the result reasonable.” Hyatt v. Anoka Police Dep’t, 691 N.W.2d 824, 826, 828 (Minn.2005) (interpreting “any person” in context of Minn. Stat. § 347.22 (2004) to include municipal owners of police dogs); see also In re PERA Police | 1 | 1 |
In Re Matter of Hildebrandtgreen1 sentence2013We conclude that section 609.035, subdivision 3, is unambiguous in stating that neither the single-behavioral-incident rule nor section 609.04 is “a bar to conviction of or punishment for any other crime committed by the defendant as part of the same conduct.” (Emphasis added.) “The word ‘any’ is given broad application in statutes, regardless of whether we consider the result reasonable.” Hyatt v. Anoka Police Dep’t, 691 N.W.2d 824, 826, 828 (Minn.2005) (interpreting “any person” in context of Minn. Stat. § 347.22 (2004) to include municipal owners of police dogs); see also In re PERA Police | 1 | 1 |
Hyatt v. Anoka Police Departmentgreen1 sentence2013We conclude that section 609.035, subdivision 3, is unambiguous in stating that neither the single-behavioral-incident rule nor section 609.04 is “a bar to conviction of or punishment for any other crime committed by the defendant as part of the same conduct.” (Emphasis added.) “The word ‘any’ is given broad application in statutes, regardless of whether we consider the result reasonable.” Hyatt v. Anoka Police Dep’t, 691 N.W.2d 824, 826, 828 (Minn.2005) (interpreting “any person” in context of Minn. Stat. § 347.22 (2004) to include municipal owners of police dogs); see also In re PERA Police | 1 | 1 |
State v. Sotogreen1 sentence2009State v. Williams, 608 N.W.2d 837, 841 (Minn.2000); State v. Soto, 562 N.W.2d 299, 304 (Minn.1997). | 1 | 1 |
Nelson v. Productive Alternatives, Inc.green1 sentence2009We apply the rules of statutory construction to the sentencing guidelines, including the canon “expressio unius est exclusio alterius.” This canon provides that “the expression of one thing is the exclusion of another.” Nelson v. Productive Alternatives, Inc., 715 N.W.2d 452, 457 (Minn.2006). | 1 | 1 |
State v. Marchbanksgreen1 sentence2006See State v. Marchbanks, 632 N.W.2d 725, 731 (Minn.App.2001). | 1 | 1 |
State v. Marquardtgreen1 sentence2004State v. Marquardt, 294 N.W.2d 849, 850-51 (Minn.1980). | 1 | 1 |
| Case | Negative | Cited |
|---|---|---|
| No negative-treatment citations attached to this issue in Minnesota. Read the followed side critically anyway. | ||
| Case | Cited | Years |
|---|---|---|
State v. Bauer
green
1 sentence2014“When conducting a single-behavioral-incident analysis for two intentional crimes, Minnesota courts consider whether the conduct (1) shares a unity of time and place and (2) was motivated by an effort to obtain a single criminal objective.”1 State v. Bauer, 776 N.W.2d 462, 478 (Minn. App. 2009) (citing State v. Williams, 608 N.W.2d 837, 841 (Minn. 2000)), aff’d, 792 N.W.2d 825 (Minn. 2011). | 1 | 2014–2014 |
State v. Williams
green
1 sentence2013Section 609.035, subdivision 1, “prohibits the imposition of multiple sentences for offences committed as part of a single behavioral incident.” Williams, 771 N.W.2d at 520 . | 1 | 2013–2013 |
Counted by distinct opinions that both name this issue and are annotated to the section; sections every opinion cites regardless of issue are not filtered here, so read the counts against the total above.